Texas Commission on Environmental Quality …ntxawma.org/postings/2017-08-03...

Texas Commission on Environmental Quality

Simple Cycle Turbine

Readily Available Permit

Qualification Criteria……………………………………………..1

Special Conditions………………………………………………….4

RAP Modeling Outline……………………………………………11

August 3, 2017

TCEQ - (APDG6406v1, Revised 05/17) RAP-SCT Qualification Criteria This form is for use by facilities subject to air quality permit requirements and may be revised periodically. Page 1 of 3

Texas Commission on Environmental Quality Readily Available Permit – Simple Cycle Turbine

Qualification Criteria

The following qualification criteria must be met in order to submit an application for the Readily Available Permit – Simple Cycle Turbine (RAP-SCT). If the facility meets the conditions of this permit, the answer should be “Yes” to each of these criteria.

If the qualifying criteria are not met, or if the applicant does not agree with the RAP-SCT conditions, the applicant will receive notice that the application has been voided. If the application is voided for these reasons, the application should seek a different type of authorization as appropriate.

I. General Requirements:

The project is for an electric utility simple cycle turbine facility.

The project is at a greenfield site.

The project is a minor source.

The customer has a compliance history classification of Satisfactory or High. • Further information on compliance history classifications can be found at:

www.tceq.texas.gov/compliance/enforcement/compliance-history/about.html. • Details on obtaining a compliance history report can be found at:

www.tceq.texas.gov/compliance/enforcement/compliance-history/get_report.html.

The facility will comply with the RAP-SCT conditions.

The emission sources included in this RAP are limited to: • Two (2) simple cycle turbines; • One (1) fire water pump; • Two (2) dew point heaters; • Two (2) lube oil vents; • Six (6) tanks; and • One (1) emergency generator engine. • Fugitive emissions • Maintenance, Startup and Shutdown (MSS) activities

The setback distance requirements from the property line to the closest emission point vary depending on the county in which the site is located. • El Paso County setback requirement is 300 meters. • Harris County setback requirement is 420 meters. • All other counties have a setback requirement of 150 meters.

II. Equipment Criteria:

Simple Cycle Turbine

Each turbine is limited to operating 2500 hours per year.

Each individual simple cycle turbine must meet the following discharge parameters: • The release height must be a minimum of 80 feet (ft.); • The temperature must be a minimum of 756 degrees Fahrenheit (°F); and • The diameter must be a minimum of 15 ft.; • The velocity must be a minimum of 52.4 feet per second (fps).

https://www.tceq.texas.gov/compliance/enforcement/compliance-history/about.html

https://www.tceq.texas.gov/compliance/enforcement/compliance-history/get_report.html

https://www.tceq.texas.gov/assets/public/permitting/air/Guidance/NewSourceReview/rap/rap-cnd.pdf


The following practices and controls represent Best Available Control Technology (BACT) for each unit: • NOX: 9 ppmvd at 15% O2 during steady state operations using dry low NOx (DLN). Installing

a selective catalytic reduction (SCR) would not be economically reasonable given the limited annual operating hours.

• CO: 9 ppmvd at 15% O2 using DLN and good combustion practices. An oxidation catalyst would not be economically reasonable given the limited annual operating hours.

• VOC: 2.0 ppmvd at 15% O2 using good combustion practices, good burner design, and firing pipeline-quality natural gas.

• SO2 and H2SO4: Firing pipeline-quality natural gas with a sulfur content not exceeding 2.0 grains total sulfur per 100 dry standard cubic feet (dscf) on an hourly basis, and 0.25 grains total sulfur per 100 dscf on an annual basis.

• PM/ PM10 / PM2.5: Firing pipeline-quality natural gas and good combustion practices. • MSS: Conducted in accordance with manufacturer’s recommendations, minimizing the

duration of the events (as required by the Special Conditions), and meeting the emission limitations on the maximum allowable emission rate table (MAERT).

Fire Water Pump

The fire water pump must meet the following discharge parameters: • The release height must be a minimum of 7 ft.; • The diameter must be a minimum of 0.33 ft.; • The temperature must be a minimum of 821°F; and • The velocity must be a minimum of 90 fps.

The fire water pump must meet the following input parameters: • The rated brake power of the engine may not exceed 184.22 horsepower (hp).

The following practices and controls represent BACT for this unit: • Meeting the requirements of 40 CFR Part 60, Subpart IIII. • Firing ultra-low sulfur diesel fuel (no more than 15 parts per million (ppm) sulfur by weight). • Limited to 100 hrs/yr of non-emergency operation. • Have a non-resettable runtime meter.

Dew Point Heater

Each individual dew point heater must meet the following discharge parameters: • The release height must be a minimum of 20 ft.; • The diameter must be a minimum of 0.67 ft.; • The temperature must be a minimum of 700°F; and • The velocity must be a minimum of 40 fps.

Each individual dew point heater must meet the following input parameters: • The design firing rate of the heater may not exceed 5.99 million British thermal units per hour

(MMBtu/hr).

The following practices and controls represent BACT for each unit: • Low NOx burners limited to 0.06 lb. NOx/MMBtu higher heating value (HHV basis). • Firing pipeline-quality natural gas.

Lube Oil Vent

Each individual lube oil vent must meet the following discharge parameters: • The release height must be a minimum of 20 ft.

The following practices and controls represent BACT for each unit: • Lube oil mist shall be minimized through the use of a mist elimination system which is

designed to achieve 99% or greater reduction of fine particulate matter (PM2.5).


Tank

Each tank must store diesel or lube oil.

Each individual tank must meet the following discharge parameters: • The release height must be a minimum of 3 ft.

The following practices and controls represent BACT for each unit: • Painted white. • Submerged fill.

Emergency Engine

The emergency engine must meet the following discharge parameters: • The release height must be a minimum of 10 ft.; • The diameter must be a minimum of 0.32 ft.; • The temperature must be a minimum of 859 °F; and • The velocity must be a minimum of 73.5 fps.

The emergency generator engine must meet the following input parameters: • The rated brake power of the engine may not exceed 1234 hp.

The following practices and controls represent BACT for this unit: • Meeting the requirements of 40 CFR 60, Subpart IIII. • Firing ultra-low sulfur diesel fuel (no more than 15 ppm sulfur by weight). • Limited to 100 hrs/yr of non-emergency operation. • Have a non-resettable runtime meter.

Fugitive Emissions

The fugitive emissions must meet the following discharge parameters: • The release height must be a minimum of 3 ft.

The following practices and controls represent BACT for these emissions: • Repair leaks as soon as possible.

Maintenance Activities

Maintenance activities must meet the following discharge parameters: • The release height of the filter and CEMS maintenance activities must be a minimum of 15 ft. • Other maintenance activities included in EPN MAINT do not have a minimum stack height

requirement.

The following practices and controls represent BACT for these emissions: • Limiting the duration of events. • Use good practices for minimizing emissions.

Special Conditions

Permit Number

1. This permit authorizes emissions only from those emission points listed in the attached table entitled “Emission Sources - Maximum Allowable Emission Rates” (MAERT), and the facilities covered by this permit are authorized to emit subject to the emission rate limits on that table and other operating conditions specified in this permit. Also, this permit authorizes the emissions from planned maintenance, startup, and shutdown (MSS).

Federal Regulations

2. The permitted sources at these facilities shall comply with all applicable requirements of the following federal regulations:

A. The U.S. Environmental Protection Agency (EPA) Standards of Performance for New Stationary Sources (NSPS) in Title 40 Code of Federal Regulations (40 CFR) Part 60:

(1) Subpart A: General Provisions

(2) Subpart KKKK: Stationary Combustion Turbines

(3) Subpart IIII: Stationary Compression Ignition Internal Combustion Engines

B. The EPA National Emission Standards for Hazardous Air Pollutants (NESHAPS) for Source Categories in 40 CFR Part 63:

(1) Subpart A: General Provisions

(2) Subpart ZZZZ: Stationary Reciprocating Internal Combustion Engines

3. If any condition of this permit is more stringent than the regulations so incorporated, then for the purposes of complying with this permit, the permit shall govern and be the standard by which compliance shall be demonstrated.

Operational Specifications

4. Opacity of emissions from sources authorized by this permit shall not exceed 5 percent averaged over any six minute period. During periods of startup, shutdown or maintenance, the opacity from the stacks shall not exceed 15 percent over any six minute period.

A. Visible emission observations shall be conducted each calendar quarter for each stack during normal operation, unless the emission unit is not operating for the entire calendar quarter. Observations shall be made at least 15 feet and no more than 0.25 miles from the emission points. Up to three emissions points may be read concurrently, provided that all three emission points are within a 70 degree viewing sector in front of the observer and the sun is positioned at the observer's back.

B. If visible emissions are observed from the stack(s), then opacity shall be determined by EPA Reference Method 9 within 24 hours of observing visible emissions. Contributions from uncombined water shall not be included in determining compliance with this condition.

C. If the opacity limits of this Special Condition are exceeded, corrective action to eliminate the source of visible emissions shall be taken promptly and documented within one week of first observation.

5. Upon request by the Executive Director of the Texas Commission on Environmental Quality (TCEQ) or any local air pollution control program having jurisdiction, the permit holder shall provide a sample and/or an analysis of the fuel fired in the gas turbines or engines, or shall allow an air pollution control agency representative to obtain a sample for analysis.

Special Conditions

Permit Number

Page 2

6. Fuel for each turbine shall be pipeline-quality natural gas containing no more than 2.0 grains total

sulfur per 100 dry standard cubic feet (dscf) on an hourly basis, and 0.25 grains total sulfur per 100 dscf on an annual basis.

7. Each turbine shall be limited to 2500 hours of operation per year, including periods of MSS.

8. Exhaust gases from each turbine shall not exceed the following concentrations in parts per million by volume, dry basis (ppmvd) at 15 percent oxygen (O2):

Pollutant Averaging Time Concentration

Oxides of Nitrogen (NOX) 3-hr rolling average 9.0

Carbon Monoxide (CO) 3-hr rolling average 9.0

Volatile Organic Compound (VOC) 3-hr rolling average 2.0

A. Each turbine’s normal operating range is from 60 to 100 percent of base load except for

periods of planned MSS.

B. Reduced load operation below base load not associated with planned MSS is authorized and not subject to the above concentration limits, provided the emission rates specified in the MAERT are not exceeded.

C. Planned startup events for each turbine are excluded from the above concentration limits. Each startup event shall not exceed one hour and is defined as the period that begins when an initial flame detection signal is recorded in the plant’s data acquisition and handling system (DAHS) and ends when the turbine enters lean pre-mix operating mode.

D. Planned shutdown events for each turbine are excluded from the above concentration limits. Each shutdown event shall not exceed one hour and is defined as the period that begins when the DAHS received a shutdown signal and exits the lean pre-mix operating mode and ends when the flame detection signal is no longer detected by the plant’s DAHS.

E. Emissions from maintenance activities (Attachment A) shall be excluded. Compliance shall be demonstrated by comparing the pollutant’s total hourly emissions as calculated or measured by the Continuous Emissions Monitoring System (CEMS) to the hourly MSS rates listed in the MAERT. The permit holder shall sum all emissions from planned maintenance activities on a rolling 12-month basis for each Emission Point Number (EPN) to demonstrate compliance with the MAERT.

9. Each dew point heater shall be designed to emit no more than 0.06 pound NOx per million British thermal unit (lb/MMBtu) (higher heating value (HHV) basis) fuel fired on a 1-hour block average.

10. The following requirements apply to each engine:

A. Fuel for each engine shall be limited to ultra-low sulfur diesel (ULSD) containing no more than 15 parts per million by weight (ppmw) total sulfur.

B. Each engine shall be limited to 100 hours per year during non-emergency situations.

C. Each engine shall be equipped with a non-resettable hour meter.

Special Conditions

Permit Number

Page 3

Initial Determination of Compliance

11. Sampling ports and platforms shall be incorporated into the design of the turbine exhaust stacks according to the specifications set forth in the TCEQ “Guidelines for Stack Sampling Facilities”. Alternate sampling facility designs may be submitted for approval by the TCEQ Regional Director.

The permit holder shall perform stack sampling and other testing as required to establish the actual quantities of air contaminants being emitted into the atmosphere from each gas turbine. The permit holder is responsible for providing sampling and testing facilities and conducting the sampling and testing operations at his expense. Sampling shall be conducted in accordance with the appropriate procedures of the TCEQ Sampling Procedures Manual and EPA Reference Methods. The TCEQ Executive Director or his designated representative shall be afforded the opportunity to observe all such sampling upon request.

Fuel sampling using the methods and procedures of 40 CFR § 60.4415 may be conducted in lieu of stack sampling for sulfur dioxide (SO2) or the permit holder may be exempted from fuel monitoring of SO2 as provided under 40 CFR § 60.4365. If fuel sampling is used, compliance with NSPS Subpart KKKK SO2 limits shall be based on 100 percent conversion of the sulfur in the fuel to SO2. Any deviations from those procedures must be approved by the Executive Director of the TCEQ prior to sampling. Fuel sampling using the methods and procedures of 40 CFR § 60.4360 may be conducted in lieu of stack testing for SO2.

A. The appropriate TCEQ Regional Office shall be contacted as soon as testing is scheduled but not less than 45 days prior to sampling to schedule a pretest meeting. The notice shall include:

(1) Proposed date for pretest meeting.

(2) Date sampling will occur.

(3) Name of firm conducting sampling.

(4) Type of sampling equipment to be used.

(5) Method or procedure to be used in sampling.

(6) Procedure used to determine turbine load during and after the sampling period.

A written proposed description of any deviation from sampling procedures specified in permit conditions or the TCEQ or EPA sampling procedures shall be made available to the TCEQ prior to the pretest meeting. The TCEQ Regional Director shall approve or disapprove of any deviation from specified sampling procedures.

B. Air contaminants and diluents from the turbine to be sampled and analyzed include NOX, CO, particulate matter (PM), VOC, SO2, opacity, and O2. Fuel sampling using the methods and procedures of the applicable NSPS may be conducted in lieu of stack sampling for SO2.

C. Each turbine shall be tested at a minimum and maximum load of the permitted operating range that is defined in this permit for the atmospheric conditions which exist during testing. Each tested load shall be identified in the sampling report. The permit holder shall present at the pretest meeting the manner in which stack sampling will be executed in order to demonstrate compliance with emission standards found in 40 CFR Part 60, Subpart KKKK for combustion gas turbines.

D. Test waivers and alternate or equivalent procedure proposals which must have EPA approval shall be submitted to the TCEQ Air Permits Division.

Special Conditions

Permit Number

Page 4

E. Sampling shall occur within 60 days after achieving the maximum operating rate, but no later

than 180 days after initial startup of the facilities and at other times when required by the TCEQ Regional Director. Requests for additional time to perform sampling shall be submitted to the appropriate regional office.

F. Copies of the final sampling report shall be forwarded to the TCEQ within 60 days after sampling is completed. Sampling reports, including distribution instructions, shall comply with Chapter 14 of the TCEQ Sampling Procedures Manual.

Continuous Demonstration of Compliance

12. The permit holder shall install, calibrate, and maintain a CEMS to measure and record the in-stack concentration of NOx, CO, and diluent gases (carbon dioxide (CO2) or O2) from each gas turbine stack.

A. The NOx and diluent gas CEMS shall meet the design and performance specifications, pass the field tests, and meet the installation requirements and the data analysis and reporting requirements specified in the applicable Performance Specification Nos. 2 and 3, 40 CFR Part 60, Appendix B. The permit holder shall assure that the CEMS meets the applicable quality-assurance requirements specified in 40 CFR Part 60, Appendix F, Procedure 1.

B. Compliance with the CEMS requirements of 40 CFR Part 60 can be demonstrated by meeting the applicable requirements of 40 CFR Part 75 provided that the holder of this permit demonstrates compliance with all applicable 40 CFR Part 60 emission standards.

C. The CO CEMS shall meet the design and performance specifications, pass the field tests, and meet the installation requirements and the data analysis and reporting requirements specified in the applicable performance specifications in 40 CFR Part 60, Appendix B, Performance Specification No. 4.

D. All CEMS shall meet the applicable quality assurance requirements specified in 40 CFR Part 60, Appendix F, except that cylinder gas audits (CGA) conducted in all four quarters may be used in lieu of the annual relative accuracy test audit. Quarterly CGAs shall be conducted at least 60 days apart. Relative accuracy exceedances (as specified in 40 CFR 60, Appendix F), CGA exceedances of ±15 percent accuracy, and any CEMS downtime shall be reported to the TCEQ regional office, and necessary corrective action shall be taken. Supplemental stack sampling may be required at the discretion of the TCEQ Regional Director.

E. If any emission monitor fails to meet specified performance, it shall be repaired or replaced immediately. If repair or replacement is not immediately feasible, the monitor shall be repaired or replaced no later than seven days after the failure is first detected by an employee at the site, unless written permission is obtained from the TCEQ Regional Office which allows for longer repair/replacement time. The holder of this permit shall develop an operation and maintenance program (including stocking necessary spare parts) to ensure that the continuous monitors are available as required. A monitor with downtime due to breakdown or repair of more than 10 percent of the facility operating time for any calendar year will be considered as a defective monitor and the monitor must be replaced within two weeks after exceeding the 10 percent threshold.

F. The monitoring data shall be reduced to hourly average values at least once every day, using a minimum of four equally-spaced data points from each one-hour period. At least two valid data points shall be generated during the hourly period in which zero and span is performed. The individual average concentrations shall be reduced to units of lbs/hr at least once every day.

Special Conditions

Permit Number

Page 5

G. The monitoring data and quality-assurance data shall be maintained by the permit holder at

the facility site. The data from the CEMS will be used to determine compliance with the conditions of this permit. During periods where the CEMS data is unavailable or not quality assured, compliance may alternatively be determined by using manufacturer emission factors or valid and representative data previously measured and recorded by the unit’s CEMS under similar operating conditions.

H. The TCEQ Regional Office shall be notified at least 21 days prior to any required relative accuracy test audit, and Regional Office personnel shall be provided with an opportunity to observe the testing.

I. If applicable, the requirements of 40 CFR Part 75, Appendices A and B, may be used as an alternative to the performance specifications and quality assurance requirements (respectively) of 40 CFR Part 60 for the NOX and O2 CEMS.

13. The holder of this permit shall either measure, or develop a program to calculate, the total mass flow rate through the stacks to ensure continuous compliance with the emission limitations specified in the MAERT. The permit holder shall calculate hourly mass emissions in pounds per hour (lbs/hr) using the measured or calculated exhaust flow rate and the measured concentrations of NOx and CO from the CEMS required in this permit.

14. The permit holder shall monitor fuel consumption from each gaseous fuel combustion device individually and continuously, using monitoring devices that are accurate to ±2.0 percent of the unit’s maximum flow and maintain, calibrate, and operate the devices in accordance with the manufacturer’s specifications. The devices shall be calibrated in accordance with the manufacturer’s recommendations or at least annually.

15. After the initial demonstration of compliance, ongoing compliance with the VOC and PM tons per year emission rates in the MAERT shall be demonstrated by calculating rolling 12-month annual emissions from emission factors (lb/MMBtu, HHV) obtained from the results of the sampling required by this permit and the monthly total heat input (MMBtu, HHV) from natural gas fuel.

Recordkeeping Requirements

16. The following records (written or electronic) shall be kept at the plant for the life of the permit. All records required in this permit shall be made available at the request of personnel from the TCEQ, EPA, or any local air pollution control program having jurisdiction:

A. A copy of this permit.

B. The initial permit application and subsequent representations submitted to the TCEQ.

C. A complete copy of the testing reports and records of the initial performance testing completed to demonstrate initial compliance.

D. Stack sampling results or other air emissions testing (other than CEMS data).

17. The following records shall be maintained by the holder of this permit in a form suitable for inspection for a period of five years after collection and shall be made available upon request to representatives of the TCEQ, EPA, or any local air pollution control program having jurisdiction:

A. The CEMS data to demonstrate compliance with the emission rates listed in the Special Conditions and the MAERT.

Special Conditions

Permit Number

Page 6

B. Raw data files of all CEMS data including calibration checks and adjustments and

maintenance performed on these systems in a permanent form suitable for inspection.

C. Records for the hourly calculated values required to determine mass flow rates from CEMS data and compliance with the MAERT shall be cumulatively added during each hour of the month and stored electronically.

D. Records of the hours of operation and the quantity of natural gas fired in the gas turbines.

E. Records of dates and times for startups and shutdowns of each turbine.

F. Records of fuel sampling conducted pursuant to 40 CFR Part 60, Subpart KKKK.

G. Records of fuel delivery including sulfur content based on receipts or chemical analyses. Fuel designated as ULSD on the receipt is acceptable.

H. Record of visible emissions or opacity observations, including corrective actions taken.

I. Records of planned maintenance activities.

Date:

Attachment A - Maintenance Activities

The following list of maintenance activities is authorized by this permit. This list is not intended to be all-inclusive of activities at the site.

Planned Maintenance Activity EPN Emissions

NOX CO VOC PM SO2

Combustion optimization1 CTG1 and/or

CTG2 X X X X X

Turbine washing online2 CTG1 and/or

CTG2 X

Miscellaneous particulate filter maintenance3 MAINT X

Gaseous fuel venting4 MAINT X

Water-based washing MAINT X

Management of sludge from pits, ponds, sumps, and water conveyances5 MAINT X

Organic chemical usage MAINT X

Inspection, repair, replacement, adjusting, testing, and calibration of analytical equipment, process instruments including sight glasses, meters, gauges, CEMS, or Periodic Emissions Monitoring System (PEMS)

MAINT X X X

Small equipment and fugitive component repair and replacement in VOC service6 MAINT X

Maintenance of storage vessels storing materials with a vapor pressure <0.5 psia MAINT X

Maintenance of storage vessels storing gasoline of other materials with a vapor pressure > 0.5 psia MAINT X

Maintenance of storage vessels storing gasoline of other materials with a vapor pressure > 0.5 psia that require clearing of the vessels to allow for entry of personnel

MAINT X

Date:

1 Includes, but is not limited to, (1) leak or operability checks (e.g. turbine over-speed test, troubleshooting), (ii) balancing, and (iii) tuning activities that occur during seasonal tuning or after completion of initial construction, combustor change-out, major repair, combustor maintenance, or other similar circumstances.

2 Involves the use of water only. 3 Includes, but is not limited to, process-related building air filters, and combustion turbine air intake filters. 4 Includes, but is not limited to, venting prior to pipeline pigging and meter proving. 5 Includes, but is not limited to, management by vacuum truck/dewatering of materials in open pits, ponds, sumps, tanks, and other

closed/open vessels. Material include water and sludge materials containing miscellaneous VOCs such as diesel, lube oil, and other waste oils.

6 Includes, but is not limited to, (i) repair/replacement of pumps, compressors, valves, pipes, flanges, transport lines, filters, and screens in natural gas, diesel oil, lube oil, and gasoline service, (ii) vehicle and mobile equipment maintenance that may involve VOC emissions, such as oil changes, transmission service, and hydraulic system service.

Air Quality Analyses for the Simple Cycle Turbine Readily Available Permit Air quality analyses (AQAs) were performed in support of the simple cycle turbine readily available permit (RAP). AQAs were performed for each of the sixteen Texas Commission on Environmental Quality (TCEQ) regions; these regions include Amarillo, Lubbock, Abilene, Dallas-Fort Worth, Tyler, El Paso, Midland, San Angelo, Waco, Beaumont, Austin, Houston, San Antonio, Corpus Christi, Harlingen, and Laredo. Click here for additional information on the different TCEQ regions, including maps and listings of the counties within each region.

The discussion below begins with an explanation on how model input data were developed prior to conducting modeling for the simple cycle turbine RAP. The discussion continues with an explanation of the modeling and the results of the analyses.

Developing Model Input Data

Prior to conducting modeling, it’s important that the model user knows the model input data requirements and understands what these data represent. For the simple cycle turbine RAP, obtaining model source input parameters for simple cycle turbines and other ancillary equipment was necessary, along with developing meteorological data sets that the model could use.

Source Input Data

In order to obtain model source input parameters for simple cycle turbines and other ancillary equipment, a review of permit files was conducted for simple cycle turbine projects that have been submitted to the agency in the past (approximately 20 different project files were reviewed). The goal was to identify the facilities and equipment that are typical for simple cycle turbine sites. Based on the review, the following facilities and equipment were identified: turbines; dew point heaters; lube oil vents; fire water pump engine; emergency generator engine; tanks for storing diesel and lube oil; fugitive emissions; and planned maintenance, start-up, and shutdown (MSS) activities associated with continuous emission monitoring system (CEMS) calibration, turbine washing, and filter change outs.

Along with identifying the different types of facilities and equipment, emission rates and source parameters used for modeling (for example, source release height, exit temperature, exit velocity, exit diameter, etc.) were compiled for the identified facilities. For the simple cycle turbines, data associated with different turbine models, operating levels, and start-up/shutdown operations were also considered as data were compiled. Once all of the applicable data were compiled for the different facilities and equipment, reasonable worst-case values were determined for use as model input data. The approach for determining reasonable worst-case values was to use high emission rates and source parameters that would lead to lower plume rise and less dispersion in order to have a conservative analysis.

Meteorological Input Data

The American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) was used to conduct the modeling analyses. The meteorological data pre-processor for AERMOD is AERMET, and AERMET version 16216 was used to process meteorological data for the analyses. As noted above, modeling was conducted for each of the sixteen TCEQ regions;

https://www.tceq.texas.gov/about/directory/region/reglist.html

therefore, AERMET was used to process meteorological data for each of the TCEQ regions. Five years of meteorological data (2011-2015) representative for each TCEQ region were processed using surface characteristic values calculated from AERSURFACE. Additionally, the ADJ_U* option within AERMET was used as meteorological data were processed. Using the ADJ_U* option is part of the regulatory package of AERMOD when site-specific turbulence data are not used in the processing.

Modeling and Results

With the model source input parameters and meteorological input data ready, the modeling can commence. The sections that follow will detail the general model setup, the results of the modeling as part of the air quality analyses, and the final documentation.

Model Setup

The modeling was conducted with AERMOD version 16216r. Based on the review of the previously submitted simple cycle turbine projects, the following pollutants were identified to be modeled: carbon monoxide (CO), sulfur dioxide (SO

2), nitrogen oxide (NO

x), particulate matter

with a diameter of 10 microns or less (PM10

), particulate matter with a diameter of 2.5 microns or less (PM

2.5), sulfuric acid (H

2SO

4), lube oil, diesel, and natural gas. For each pollutant, all

applicable sources that emit the pollutant were modeled together:

• NO2 and CO - two turbines, two dew point heaters, one fire water pump engine, one

emergency generator engine, and planned MSS activities associated with CEMS calibration for two turbines

• SO2 and H

2SO

4 - two turbines, two dew point heaters, one fire water pump engine, and

one emergency generator engine

• PM10

and PM2.5

- two turbines, two dew point heaters, two lube oil vents, one fire water pump engine, one emergency generator engine, and planned MSS activities associated with filter change outs and turbine washing for one turbine

• Diesel – diesel storage tank

• Natural Gas – fugitive piping

• Lube Oil – two lube oil vents, lube oil storage tank, and fugitive piping

All of the modeled sources were co-located at the center of the site. This technique will provide conservative results since the cumulative impact of all sources is maximized.

To account for conversion of NOx to NO

2, the ambient ratio method 2 (ARM2) was used in the

modeling analyses. This is consistent with EPA guidance for conducting a Tier 2 screening approach for NO

x emissions.

The modeling was conducted using a receptor grid that started at a distance of approximately 150 meters from the modeled sources. Therefore, a setback distance of 150 meters from the facilities to the nearest property line will be needed. This distance is driven by the ancillary equipment given that they have shorter release heights and/or plumes with little plume rise.

Results

Modeling was conducted for a number of pollutants for comparison with the National Ambient Air Quality Standards (NAAQS), state property line standards, and Effects Screening Levels (ESLs). For pollutants with a state property line standard (SO

2 and H

2SO

4) and pollutants with an

ESL (lube oil, diesel, and natural gas), the modeling results are less than their corresponding standards and ESLs, respectively. This includes the more restrictive SO

2 state property line

standards for Galveston, Harris, Jefferson, and Orange Counties. For the criteria pollutants, the results are either less than de minimis levels or are less than the NAAQS when the model predictions are added to conservative background concentrations.

The approach for selecting background concentrations was to be conservative. For some pollutant/averaging time combinations, using the highest background concentration from 2013-2015 state-wide with the model predictions gives total concentrations less than the NAAQS. When the highest background concentration was too conservative, refinements were made, but conservative values were still used. For example, using the highest 98th percentile of the annual distribution of the maximum daily 1-hr concentrations for 1-hr NO

2 from 2013-2015

state-wide, and not a three-year average of the 98th percentile of the annual distribution of the maximum daily 1-hr concentrations (which is the design value concentration for 1-hr NO

2).

For PM, the background concentrations were based on the design value concentrations. For example, using the three-year average (2013-2015) of the 98th percentile of the annual distribution of the 24-hr concentrations for the 24-hr averaging period of PM

2.5. When the

highest design value concentration state-wide was too conservative, a conservative regional value was used. As an example, consider TCEQ Region 8; this region does not have a PM

2.5

monitor located within it, and using the highest design value concentration for PM2.5

state-wide is too conservative. Monitoring data from monitors located in surrounding TCEQ regions (TCEQ Regions 7, 9, 11, and 13) were reviewed, and the highest design value concentration from these four regions was used as a conservative value for TCEQ Region 8.

Note that there are two areas that will have a different setback distance (150 meters) based on the results of the analyses. The first area is El Paso County; since there is a PM

10 nonattainment

area in El Paso County, modeling results were evaluated to determine when PM10

predictions are less than de minimis [5 micrograms per cubic meter (µg/m3)]. Based on the evaluation, a setback distance of 300 meters from the facilities to the nearest property line will be needed for sites proposed to be located in El Paso County. The second area is Harris County; given the annual PM

2.5 background concentrations for two monitors located in Harris County (the Clinton

Dr. and Aldine monitors), modeling results were evaluated to determine when annual PM2.5

predictions together with background concentrations are less than the annual PM

2.5 NAAQS (12

µg/m3). Based on the evaluation, a setback distance of 420 meters from the facilities to the nearest property line will be needed for sites proposed to be located in Harris County.

Documentation

The documentation is already complete for the air quality analyses. A report has been written for each of the sixteen TCEQ regions, and it will be included as part of the technical review documentation.


ePermits

August 14, 2016 Page 1 of 3

How to Register with STEERS (ePermitting) System Attention:

• A STEERS account is required in order to access the ePermitting system. If you submit your Renewal or new Notice of Intent (NOI) application online, the discounted fee is $100 cheaper. The fee is $100 for a Renewal Industrial Notice of Intent (INOI) or No Exposure Certification (NEC).

• If you go directly to the e-Pay website and pay for the authorization, it will not automatically renew your existing permit nor provide you a new permit and you will not receive the discount. You will need to complete the process by submitting the completed and signed NOI application through STEERS (ePermitting system).

• If you are not using the ePermitting system and are submitting your NOI via paper, then you will have to fill out, sign, and mail in the paper forms to the Stormwater Processing Center and mail your fee separately to the Cashier’s Office. The fee for the paper NOI or NEC is $200.

When creating a new STEERS account you will need to select Stormwater General Permits as the STEERS Program Area. The account will be on probation until you sign the STEERS Participation Agreement (SPA). A copy of the SPA must be received by the TCEQ. The paper SPA can be mailed to STEERS or signed electronically if you have a valid class C Texas Driver’s License (TDL). If signed using your driver’s license, the activation occurs that same day. If the SPA is submitted by mail, it will be 3-10 days before full access is granted, depending on the mailing format used. The paper SPA allows for those who cannot sign electronically, such as out-of- state residents, to apply for permits online. Signing the STEERS agreement only activates the user account; it does not renew or provide a permit. If you have an existing STEERS account or you are a new user, you will need to log on to STEERS with your account number and password to start the permit authorization/renewal process. For questions related to your STEERS account, please contact STEERS by e-mail at [email protected] or by telephone at (512) 239-6925.

To apply online through ePermits, you must first create an account with STEERS by following these steps:

1. Go to this website: https://www3.tceq.texas.gov/steers/ (You must use “https”)

2. Select I Need: to create a new account

3. Read the information and click Create New Account

4. Enter all required information including your name, company name, and title. (If there is no company name or title, enter Owner or Individual).

5. Enter your e-mail address. It must be unique.

6. Enter your phone number and mailing address.

7. Click Next.

8. The next page displays your information for review, you can click previous to make changes or click next if the information is correct. The next screen may provide a list of existing STEERS accounts, if there are potential duplicates with your name. If none pertain to you, click Next. Your ER account number will be immediately emailed to you once you click the Next button. Fill in the security question information. It is recommended that you save this information in a safe place for

mailto:[email protected]

https://www3.tceq.texas.gov/steers/


future use. Each time you log in, you will be asked to answer one security question. NOTE: During login, if the answer provided to the question is incorrect (or is not the answer provided during creation of the security questions), STEERS will have you answer the next security question. You will have 3 chances before STEERS locks you out of your account.

9. Click Save.

10. Select program area “Stormwater General Permits (EPR_ SW)” from the drop down menu

11. Click Go.

12. Select the access type that you need for using ePermits. 30 TAC §305.44 requires the Executive Officer of a company or the person if owned by an individual to sign the application. Signature for applications cannot be delegated authority.

Owner/Operator: Select Stormwater Sign-view, create, delete, modify, pay, sign, and submit

Consultant/ Delegated Preparer: Select Stormwater Preparer- view, create, delete, modify, pay, and submit

13. Select your relationship to the facility:

Owner/Operator: Select “My employer is the facility…”

Delegated Preparer: Select “My employer is the facility…”

Consultant: Select “My employer is not the facility…”

14. Select who is authorizing the account:

Consultant/ Delegated Preparer: Select “I, [Your Name], am applying for read, edit, or preparer role…”

Owner/Operator: Select “I, [Your Name], am applying for a signatory role…”

15. Click Add Access

16. Once the information has been updated, you will received the following pop-up “Your EPR_SW access has been updated. You can make additional changes or press cancel to return to Account Information.” If you agree to the information provided, click Cancel

17. Verify that your account information is accurate. The Account Status will show PROBATION until you sign the STEERS Participation Agreement (SPA).

18. At the top of the page, select eSign SPA or Paper SPA

Paper SPA – This allows you to print out the SPA, sign it and mail it to the address shown on the SPA. Once your paperwork is processed, you will receive an email notification that your probationary status was removed and you will have full access to STEERS.

eSign SPA – If you have a valid Class C Texas Driver’s License, you can eSign the application. Simply enter your personal information and TDL numbers where asked, click both check boxes, then click eSign SPA.

19. Check your email for the Welcome to STEERS Account Creation email.


20. Follow the instructions in the email to set up your account password.

21. Logon to STEERS by entering your newly created Account Number and Password to start the renewal/application process.


Expedited Permitting Program

Page i

Implementation of the Expedited Permitting Program

Table of Contents

Request for Expedited Processing ...............................................................................................1

Surcharge Amounts .........................................................................................................................1

Application and Review Process ..................................................................................................2

General Information ................................................................................................................2

New Source Review (NSR) ......................................................................................................3

Pre-Application ..........................................................................................................................3

Application Submittal .............................................................................................................4

Application Review ..................................................................................................................4

Other Topics ..............................................................................................................................5

Permits by Rule (PBR) and Standard Permits with no public notice .........................6


Technical Review .....................................................................................................................6

Federal Operating Permits (Title V) ....................................................................................7


Technical Review .....................................................................................................................7

Application Deficiencies ........................................................................................................7

Public Notice Procedures ...............................................................................................................7

Response to Comments (RTC) ...............................................................................................8

TCEQ-(APDG 6258v6, Revised 09/16) Implementation of the Expedited Permitting Program Page 1 of 8

Request for Expedited Processing

Title 30 Texas Administrative Code (TAC) Chapter 101, Subchapter J allows applicants to request the expedited processing of an application filed under 30 TAC Chapters 106, 116, or 122. Subject to the availability of commission resources for expediting permit applications, the Texas Commission on Environmental Quality (TCEQ) may expedite the processing of the application. The applicant should demonstrate that the purpose of the application will benefit the economy of this state or an area of this state.

To expedite an application, the applicant must submit the Form APD-EXP (Expedited Permitting Request Form), the appropriate surcharge, and the Form APD-APS (Air Permitting Surcharge Payment Form). Form APD-EXP can be found on the web at www.tceq.texas.gov/assets/public/permitting/air/Forms/NewSourceReview/20706.pdf. Form APD-APS can be found on the web at www.tceq.texas.gov/assets/public/permitting/air/Forms/NewSourceReview/20707.pdf.

For new applications, attach the APD-EXP form and a cover letter specifying the request to expedite the processing of your project with the application that you submit to the Air Permits Initial Review Team (APIRT). With the application submittal, the applicant will also submit the surcharge along with Form APD-APS to the TCEQ’s cashier’s office at the address indicated on the form.

For pending applications, an applicant only needs to submit the form APD-EXP along with a cover letter to APIRT. The applicant will also submit the surcharge along with Form APD-APS to the TCEQ’s cashier’s office at the address indicated on the form.

The applicant will receive an acceptance or denial letter from the TCEQ. The letter will be transmitted to the applicant by e-mail. If a request is denied, the surcharge will be returned to the applicant.

For permits by rule (PBRs) and standard permits that do not require public notice, applicants are required to use the ePermits process to expedite the processing of the application. No hard copy applications or requests will be accepted. The ePermits process will ask a few questions regarding expediting and then allow payment of the surcharge.

Surcharge Amounts

To process a permit application as part of the expedited permitting program, the Air Permits Division (APD) requires a surcharge. The purpose of the surcharge is to fund additional resources to expedite the application. The surcharge must be submitted along with the expedited request. Projects submitted through the ePermits system will be paid through ePay. The application will not be expedited until TCEQ has verified that the appropriate surcharge has been received.

The surcharge amounts for the various air permit projects are listed as follows:

• PBRs and Standard Permits (which do not require public notice) - $500 (non-refundable, flat surcharge)

• Standard Permit (with public notice requirements) - $3,000

https://www.tceq.texas.gov/assets/public/permitting/air/Forms/NewSourceReview/20706.pdf

https://www.tceq.texas.gov/assets/public/permitting/air/Forms/NewSourceReview/20707.pdf


• Title V General Operating Permit (GOP) - $3,000

• Title V Site Operating Permit (SOP) - $10,000

• New Source Review (NSR) case-by-case permit - $10,000

• Federal NSR permits (Prevention of Significant Deterioration (PSD) including greenhouse gas PSD, Nonattainment (NA), Plantwide Applicability Limit (PAL), and Hazardous Air Pollutant (HAP)) - $20,000

There is no additional surcharge for an NSR case-by-case permit, which accompanies a Federal NSR Permit; only the Federal NSR permit surcharge applies. Only one surcharge is required when applying for multiple federal permits.

Refunds will be processed for projects with a remaining surcharge balance amount of $450 and greater, with the exception of PBRs and standard permits with no public notice. A minimal (5-10%) percentage of the surcharge will used to cover other costs incurred by expediting the processing of applications.

The applicant (specifically the contact person indicated on the Form APD-EXP) will be contacted by e-mail prior to the depletion of the initial surcharge amount. If the applicant elects not to provide additional funding to continue with the expedited process, the application will revert to a non-expedited project and will be reviewed according to standard agency timeframes. The project may also be re-assigned to a different reviewer.

Application and Review Process

General Information

The length of time to complete the air permitting process depends on factors such as the complexity of the application, APD workload and staff availability, and required public participation timeframes.

Missing or incomplete required information or documentation in the permit application is a key factor that delays the processing of a permit application. When the application does not provide sufficient administrative or technical information, the APD staff must contact the applicant to obtain the required information. Therefore, one of the best ways to improve permit timeframes is to supply as much of the necessary information as possible in a technically complete application.

In addition, APD recommends that the applicant contact permitting staff in the planning phases of a project to address some issues that require long lead times to complete. For example, testing to develop emission factors, air quality analysis issues and modeling protocols should be discussed prior to submittal of the application.


Projects with excessive applicant initiated delays will be removed from the expedited permitting program. Some common examples of applicant delays which can cause an expedited project to be removed from the program are (not intended to be an all-inclusive list): change in project scope, requests for additional time to respond to deficiencies, multiple deficiency requests for the same administrative/technical information, lags in newspaper publication, or applicant’s overall lack of response to APD initiated requests. Deficiency letters will remind applicants of the possible removal from the expedited program. If an application is removed, a letter will be sent notifying the applicant the project is no longer part of the expedited permitting program and the remaining surcharge balance will be refunded.

New Source Review (NSR)

Pre-Application

Pre-Application Meeting (recommended, but not required)

• Prior to submittal of the application package, the applicant may contact the appropriate APD section manager to schedule a pre-application meeting. The meeting may be a phone conference.

• APD assigns a permit reviewer to the project. This assignment is subject to change.

• At least three working days prior to the pre-application meeting, the applicant submits the following information to the permit reviewer, preferably electronically. This information may be modified by the permit reviewer as is determined to be appropriate for the nature or characteristics of the project:

o An overview of the project, including a description of the processes involved and the types of emissions (contaminants and approximate quantities);

o A discussion of federal applicability including netting evaluation, if applicable;

o A discussion of best available control technology (BACT);

o A list of permitting questions to resolve in the meeting (BACT, impacts review strategies, calculation methodology, rule applicability, etc.);

o A draft application and modeling protocol, if available; and

o Anticipated submittal date and project timing (e.g., start of construction).

• During the pre-application meeting, the TCEQ staff and the applicant will discuss the expectations for the applicant to stay on the expedited track and an anticipated timeframe for the project.

Draft Application

• Prior to submittal of the formal application, the applicant may provide a draft application and modeling protocol (if applicable) for preliminary evaluation by TCEQ staff.

• Draft applications and modeling protocols should be submitted at least three weeks prior to the planned, formal application submittal date.


• A permit reviewer reviews the draft application and the Air Dispersion Modeling Team (ADMT) staff review the modeling protocol (if provided). Staff will discuss any deficiencies or questions with the applicant within seven days of the receipt of the draft application and modeling protocol. The permit reviewer (and ADMT staff if needed) will work with the applicant to resolve those deficiencies and/or questions prior to the application being submitted.

Application Submittal

• The applicant submits the Form APD-EXP, the appropriate surcharge, and the Form APD-APS. The APD-EXP form and a cover letter specifying the request to expedite the processing of the project should be submitted to the APIRT. The surcharge along with Form APD-APS should be submitted to the TCEQ’s cashier’s office at the address indicated on the form.

• All requirements for the application including technical information to support the PI-1, PI-1R, or PI-1S, must be included in the application for it to be declared “administratively complete.”

• If the applicant has conducted SCREEN modeling to determine compliance with standards or meet effects screening level thresholds, the modeling results and supporting modeling documentation may be included in the application. However, additional modeling may be required if the applicant’s proposed operational scenarios, control technology, emission rates, or other representations change after submittal. In addition, a modeling protocol should be provided if the applicant did not provide it during pre-application. A second modeling protocol should be provided to address any identified issues during pre-application. If the applicant does not address all issues in the second modeling protocol, the application may be voided in accordance with APD’s current voidance procedures.

• The applicant will receive an email containing a letter that states whether or not the application has been accepted into the expedited permit program. The application will not be expedited until TCEQ has verified that the appropriate surcharge has been received.

Application Review

Enhanced Administrative Review (EAR)

• Permitting and modeling staff review the application and draft a deficiency letter if needed.

• All deficiencies will be combined into one letter and sent to the applicant. The applicant has 10 days to respond to the deficiency letter.

• The permitting staff evaluates the applicant’s deficiency response. If the response is not acceptable, the application will be voided in accordance with APD’s current voidance procedures.

Technical Review – New Source Review (NSR)

• The permit reviewer conducts the technical review including BACT, calculations, federal applicability, and technical completeness.


• The permit reviewer follows the deficiency guidelines in the “Deficiencies” section for requesting additional information and preparing the permitting documents.

• Once emission rates are verified, the permit reviewer requests a complete Air Quality Analysis (AQA) that follows the approved modeling protocol or an analysis using the Modeling and Effects Review Applicability (MERA). The permit reviewer may void the application if the applicant fails to provide a complete and accurate response in the time specified.

• The permit reviewer reviews the AQA report or MERA analysis. If the AQA represents essential portions of the technical review used to determine BACT and impacts, the permit reviewer transfers the report to the ADMT.

Modeling Audit

• ADMT provides the permit reviewer with results of the first review and associated deficiencies to transfer to the applicant. If the applicant does not address all issues in the second modeling protocol, the application may be voided in accordance with APD’s current voidance procedures.

• If the air dispersion modeling does not pass the modeling audit two times, the permit reviewer may void the application in accordance with APD’s current voidance procedures.

• If the AQA requires impacts review by the Toxicology Division, the permit reviewer will coordinate with Toxicology staff.

Draft Permit

• The permit reviewer provides the draft permit to the applicant as well as the appropriate TCEQ Regional Office.

• Once written comments have been received within 30 days, the permit reviewer addresses the comments and updates the draft permit as appropriate. If substantial changes are made, the permit reviewer sends out a revised draft as needed to the applicant and the TCEQ Regional Office.

• The applicant is sent the second public notice package. Applicants must follow the applicable public notice requirements.

• The applicant communicates the publication schedules for the appropriate newspapers to the permit reviewer so that the anticipated publication date can be set.

• The applicant is responsible for providing tear sheets, affidavits, and the public notice verification form to the permit reviewer and to the Office of the Chief Clerk (OCC) in accordance with the timeframes established in the second public notice package instructions.

Other Topics

Deficiencies

The permit reviewer may send deficiency letters by email or mail directed to the listed technical contact and/or company official.


• If the applicant does not provide complete and accurate responses to the deficient items within 30 days, the permit reviewer may grant a 15-day extension. TCEQ staff will hold a conference call with the company official (listed on the application) to discuss the project and the consequences of a void.

• If the applicant has not provided complete and accurate responses to the deficient items at the end of the 15-day extension, the permit reviewer may recommend to management that the project be voided in accordance with APD’s current voidance procedures.

Permits by Rule (PBR) and Standard Permits with no public notice


The applicant submits requests for expedited processing of the application via ePermits www3.tceq.texas.gov/steers/. The applicant will also pay the $500 nonrefundable surcharge at this time. Note: ePermits must be used for all PBRs and Standard Permits (with no public notice requirements). The surcharge will be paid through the ePermits system.

• All requirements for the application including technical information must be included in the application for it to be declared “administratively complete.”

Technical Review

• The project is received by the section and assigned to the permit reviewer.

• The permit reviewer initiates technical review. Technical Review includes:

o Federal and state applicability

o Emissions calculations, process descriptions, and technical completeness

o Impacts review (if applicable)

o Any NSR permit-related review

o Emissions table completion

o Site review (if applicable)

• Deficiencies:

o The applicant will receive a phone call and email explaining any deficiencies. The applicant will have five days to submit a complete and accurate response to the deficiency.

• The applicant will receive an authorization letter and emissions table by email (ePermits) or by mail.

https://www3.tceq.texas.gov/steers/


Federal Operating Permits (Title V)


• The applicant submits the Form APD-EXP, the appropriate surcharge, and the Form APD-APS. The APD-EXP form and a cover letter specifying the request to expedite the processing of the project should be submitted to the APIRT. The surcharge along with Form APD-APS should be submitted to the TCEQ’s cashier’s office at the address indicated on the form. Copies of the application must also be submitted to the appropriate TCEQ regional office and the Environmental Protection Agency (EPA) Region 6.

• The applicant will receive an email containing a letter that says whether the application has been accepted into the program. Once the applicant receives the letter confirming acceptance, the applicant can proceed with submitting the Form APD-APS (Air Permitting Surcharge Payment form) and the surcharge as indicated in the notice and described in the “Surcharge Amounts” section of this guidance document. The surcharge must be submitted within 10 days.

• The application will not be expedited until TCEQ has verified that the appropriate surcharge has been received.

Technical Review

• The permit reviewer initiates technical review. Technical review includes:

o All applicable state and federal requirement determinations

o Compliance Assurance Monitoring/ Periodic Monitoring (CAM/PM) evaluations

o Technical completeness

Application Deficiencies

• The permit reviewer may send deficiency letters by email or mail directed to the listed technical contact and/or responsible official (RO).

• The applicant should respond to any deficiencies as expeditiously as possible, but no later than 30 days from the date of the email or letter, in order to prevent delays in the issuance of the permit. Note that the permit reviewer may request a shorter deadline. APD management must approve any requested extension.

• Failure to respond to application deficiencies within the timeframe requested by the permit reviewer may result in a voidance of the expedited project.

Public Notice Procedures

• Public notices for expedited projects will include the following sentence in the text of the notice: “This application is being processed in an expedited manner, as allowed by the commission’s rules in 30 Texas Administrative Code, Chapter 101, Subchapter J.”


• Applicants should verify that the expedited language is included in the notice published in the paper. Omitted language could result in republishing.

• Applicants will not be required to re-publish notice if notice requirements have been fulfilled prior to requesting expedited permitting review.

Response to Comments (RTC)

If comments are received during the public notice period, APD will work with the Office of Legal Services to complete the official RTC.

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